VARNICOLR CHEMICAL CONTRIBUTED NDMA TO THE ELMIRA DRINKING WATER AQUIFERS

MOE In Full Coverup Mode For The Last Twenty-Nine Years

NDMA is one of a very few chemicals that is so incredibly soluble that it immediately dissolves into groundwater and then moves with the groundwater at it's normal rate of speed. Most other chemicals, organic and inorganic, are somewhat "retarded" by temporarily bonding with soil particles as they flow in the slowly moving groundwater. As a result geoscientists will usually spot inorganics (non carbon compounds) moving off a contaminated site prior to organics such as hydrocarbon solvents. NDMA however leads the way for both. The bad news with NDMA is that it can be drawn into drinking water wells long before more conventionally tested for compounds such as benzene, toluene, chlorobenzene, trichloroethylene etc. are ever discovered. I believe this is exactly what happened in Elmira thus exposing the population to NDMA in their drinking water years before the MOE tested for and found it in the south wellfield in November 1989. Why the MOE never tested many years earlier when they and Uniroyal knew it was being produced on site is another matter.

NDMA can be formed in acidic environments in the presence of dimethlamine (DMA). DMA was used as a raw material at Uniroyal Chemical, Nutrite, and Varnicolor Chemical. The MOE knew all of that decades ago as well. At the source NDMA can be relatively quickly flushed from the sub-surface as it tends not to be "retarded" by soils once the precursers (DMA) and other conditions have been removed or changed. NDMA while readily broken down in surface water from sunlight is amazingly persistent in groundwater. It also has an extraordinarily low Ontario Drinking Water Standard (ODWS) of 9 parts per trillion (ppt) or .009 parts per billion (ppb). Therefore even when the source of the compound has been eliminated it can continue moving in the groundwater away from the source for many decades as it has here in Elmira.

Back in 1990 NDMA was found in the Varnicolor Surficial Aquifer at a maximum of fifty times higher than the ODWS. In both 1990 and 1991 it was found off-site in nearby shallow wells to the north, south and east, close to but below the ODWS. Many other Varnicolor chemicals and solvents were also found in nearby shallow, off-site wells. The testing in either the Surficial or Upper Aquifer for NDMA was not remotely extensive either by number of monitoring wells nor by number of dates testing occurred. The deeper testing on the Varnicolor site itself was essentially non-existent for the first fifteen or sixteen years after the south wellfield was shut down for NDMA contamination.This included the one well (M2-1) on-site drilled down to the fourty foot depth and just into the Upper Aquifer. As soon as the south wells were shut down this well miraculously was taken out of service and never tested again for anything. CH2MHILL Consultants who examined possible sources in Elmira for NDMA contamination were in a conflict of interest position with Varnicolor Chemical as Varnicolor were clients of theirs right up until the Region of Waterloo asked them to work on the Elmira-St.Jacobs Water Supply Project in 1991.

The MOE have been extorting or perhaps persuading is a better term, Elmira Pump, the owners of the former Varnicolor site to clean up the site since 1999/2000. They have been extremely careful to keep all the data out of the public realm where it could embarass the MOE almost into extinction. Can you imagine if Doug Ford and his band of merry mischief makers and expense slashing folks ever knew how badly the MOE really messed up in Elmira? Can you imagine if they understood that all against the public interest, the MOE had been hiding evidence of their incompetence for the last 29 years? It just might be the formal end of the MOE as we know it.

Even after all these decades the MOE have been very careful not to test for NDMA as much as possible in and around the Varnicolor site. Deep wells were finally ordered in 2005, fifteen years after they were first ordered in a MOE Control Order and then unilaterally dropped. To my knowledge NDMA may have been tested for once in one deep well on site since then. That's it. You will never find what you carefully avoid testing for.

Lastly, contrary to the Golder Report and others, the Surficial Aquitard (SAT) on the Varnicolor site does not consist of clay and does not cover the entire site. It consists of silts intermixed with gravel, sand and even cobbles in places. Also the SAT thins to nothing in the south-west and easterly directions. This allows direct access to the Upper Aquifer (UA) and the Upper Aquitard (UAT) below it which also has "windows" or openings in it allowing direct access of contaminants into the drinking water aquifers further below. Just like at Uniroyal, once contaminants have hit the bare ground it's only a matter of time before Elmira residents are drinking them.